One of the problems that a UK resident company may face when it receives a dividend from an overseas company is that of double taxation. This is much less likely to happen since the Finance Act 2009 rewrote the rules relating to the tax treatment of dividends received from non-UK resident companies1. The rules are extremely complex, but the upshot of the new regime is that most dividends and distributions received by a UK resident company, whether from a UK resident or non-UK resident company, will be exempt from UK corporation tax2.
Where a UK resident company is unable to claim an exemption for dividends received from an overseas company, there is likely to be a substantial